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Matt Musano

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Yet Another State Effort to Narrow Public Law 86‑272 Heads to Court

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States are continuing to try to limit the scope of Public Law 86‑272 (“P.L. 86-272”), and a recently filed Wisconsin case highlights this trend. On January 28, 2026, Crutchfield Corporation and Crutchfield New Media, LLC (collectively, “Crutchfield Companies”) filed a declaratory judgment action in the Wisconsin Circuit Court for Dane County against the Wisconsin Department of Revenue, the Secretary of Revenue, and the Wisconsin Attorney General, challenging a Wisconsin administrative regulation that interprets P.L. 86‑272.…

California Court Allows Three‑Factor Formula based on Alternative Apportionment and Invalidity of Special Industry Regulation

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A recent decision out of the Los Angeles County Superior Court marks a significant win for taxpayers involving the use of alternative apportionment and successful challenges to the Franchise Tax Board’s (“FTB”) regulations, which the court found to be inconsistent with the statute as applied. On February 26, 2026, the court in Smithfield Packaged Meats Corp. v. California Franchise Tax Board ordered the FTB (in  a Proposed Statement of Decision, which becomes final after an…

New York Appellate Court Affirms Entity‑Level QETC Requirements for Combined Groups

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In Matter of Charter Communications, Inc. v New York State Tax Appeals Tribunal, CV-24-0971 the New York Supreme Court, Appellate Division, Third Department (New York’s intermediate appellate court, the “Court”) recently held that Charter Communications, Inc. and its combined affiliates were not eligible for the reduced qualified emerging technology company (“QETC”) corporate franchise tax rate. The Court agreed that each member of a combined group must independently meet the QETC definition for the group to…

Pennsylvania Supreme Court Strikes Down Pittsburgh’s “Jock Tax” on Nonresident Performers

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In a unanimous decision issued on September 25, 2025, the Pennsylvania Supreme Court invalidated the City of Pittsburgh’s controversial Nonresident Sports Facility Usage Fee (commonly referred to as the “Jock Tax”), a 3% levy imposed solely on nonresident athletes and entertainers who earn income at the City’s publicly funded sports stadiums. Pittsburgh residents were exempt from the fee. The Court held that the tax violated the Uniformity Clause of the Pennsylvania Constitution, which requires that…

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